Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT adjudicated transfer pricing and corporate guarantee fee (CGF) disputes. For A.Y. 2015-16, the Tribunal remanded transfer pricing adjustments to the Assessing Officer (AO) for verification of internal and external Transactional Net Margin Method (TNMM) applied for export transactions with associated enterprises. Regarding CGF, the Tribunal allowed the claim at 0.19% for A.Y. 2015-16, consistent with judicial precedents. For A.Y. 2016-17, the Tribunal permitted CGF only up to 0.5%, disallowing the excess 0.12%. The revenue's grounds were partially allowed, with the matter being statistically remanded for further examination and providing the assessee an opportunity to present additional details.
ITAT adjudicated transfer pricing and corporate guarantee fee (CGF) disputes. For A.Y. 2015-16, the Tribunal remanded transfer pricing adjustments to the Assessing Officer (AO) for verification of internal and external Transactional Net Margin Method (TNMM) applied for export transactions with associated enterprises. Regarding CGF, the Tribunal allowed the claim at 0.19% for A.Y. 2015-16, consistent with judicial precedents. For A.Y. 2016-17, the Tribunal permitted CGF only up to 0.5%, disallowing the excess 0.12%. The revenue's grounds were partially allowed, with the matter being statistically remanded for further examination and providing the assessee an opportunity to present additional details.
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